I am writing with regards to the evidence released to youon April 11, 2002 by the Environmental Bureau of Investigation that showed toxic discharges from the Technoparc site are contaminating the St. Lawrence River.

This position runs directly contrary to the evidence presented to Environment Canada on April 11. Included in our report were photographs of the toxic slicks escaping the booms on several occasions, lab analysis of these slicks that confirms high concentrations of PCBs and PAHs, and an assessment by an independent biologist:

The purpose of the booms seems to have been to contain a black, tarry substance that we observed as variously sized blobs emerging from between and under the stones at the water’s edge within the boomed areas. However, this purpose was being totally defeated by the velocity of the water . . .The turbulent water was observed carrying the blobs over and under the booms and into the river proper . . .

The sheen would dissipate within the boomed area, then be carried by wave action from the boomed area into the river and ultimately be carried downstream. (Page 2)

In addition to the statements by Mr. Dillenbeck and investigators from the Environmental Bureau of Investigation and Sociéte pour Vaincre la Pollution, an inspector from Environment Canada confirmed last January that the City of Montréal removes the booms during the winter in order to avoid losing them to the ice floes.

By tying the booms to the shoreline during the winter months, they cannot possibly “do a good job of collecting the PCBs.” This observation was confirmed during a visit to the Technoparc site in January 2002 when EBI and SVP investigators discovered a 400-metre long toxic slick running down the St. Lawrence River. The booms, as you may note from our photographs, were secured to the shoreline and doing little to contain the discharges.

We are very concerned by your current position on the case, as it appears that you have made a decision not to conduct a Fisheries Act investigation based on flawed information. If you have not yet received a hard copy of this report, you can view it on our web site, www.e-b-i.net, or contact us and we will be happy to send one to you. The evidence presented in this report clearly provides Environment Canada investigators with reasonable grounds to initiate a full investigation.

We urge you to consider the evidence presented April 11. We would also like to remind Environment Canada that the toxic discharges from the Technoparc site are not isolated incidents, but in fact unabated discharges that have been contaminating the St. Lawrence River for years. The seriousness with which other organizations – such the U.S. Environmental Crimes Task Force and the Atlantic Enforcement Branch of Environment Canada – treat pollution crimes sets clear precedent for a diligent and thorough response to the Technoparc contamination.

When 15,000 gallons of industrial oil was spilledinto Detroit’s Rouge River recently, more than 150 employees from the U.S. Coast Guard, the U.S. Environmental Protection Agency, the FBI, the U.S. Customs Service, the Michigan State’s Attorney’s Office, and the Michigan State Police were called in. Investigators are working to determine who is responsible while the cleanup is underway in order to lay charges and recover costs plus damages.

The alarming levels of PAHs and, in particular, PCBs being discharged into the St. Lawrence River from the Technoparc site are every bit as concerning as the industrial oil spilled into the Rouge River. Once again, we formally request that Environment Canada launch an official investigation.